Yes. But if there are going to be ways of moving prescription RLD NDA approved products from prescription to the OTC, it would seem that doesn’t automatically translate into a new monograph product. It does not open flood gates for everybody in the market to come and attempt to make this without any type of regulation. So there is a need for follow on or ANDA switch or you can go from a generic to the OTC market.
There is no additional testing required because you have already done bioequivalence and shown the FDA that it is same as the RLD. You would be just updating your label and letting the FDA know about it.